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Real Estate Strategies Update - Divine Mitigation and the Statute of FraudsA recent opinion issued by the Virginia Supreme Court is certain to impact principal-agent relationships and the payment of real estate commissions in commercial and residential transactions. In C. Porter Vaughan, Inc. Realtors v. Most Rev. Francis X. DiLorenzo, Bishop of the Catholic Diocese of Richmond, 279 Va. 449, 689 S.E.2d 656 (2010), the Supreme Court concluded that the statute of frauds was not a bar to an oral agreement to pay a real estate brokers commission in a commercial real estate transaction. By Real Estate Strategies Group